My client, Mr A, owned a trading company 100%, Company A. He also owned Company B 50% with one other shareholder.
Company A has purchased the 50% shares in company B from the other shareholder. We now have a structure where Co. A holds 50% of the shares in Co B, with the other 50% owned by Mr A.
Mr A wants to transfer the trade and assets of Co B up to Co A and get rid of Co B.
What is the tax treatment here? They are not an official group as it is less than a 50% subsidiary, so there will be no tax neutral transfer of assets between the group. Is there any way of doing this tax efficiently?
Any help appreciated.